Mr. Edward M. TaylorI beg to move, in page 200, line 37, at the end to insert:
(c) the aggregate income taken into account in computing foreign tax shall be related to the aggregate foreign tax applicable to such income.
§ The Temporary Chairman (Mr. Grant-Ferris)It may be for the convenience of the Committee if, with this Amendment, we also discuss Amendments No. 414, in page 201, line 13, to leave out sub-paragraph (2), and Amendment No. 415, in page 201, line 48, after first "tax", to insert:
and for the purposes of any credit for foreign tax".
Mr. TaylorThank you, Mr. Grant-Ferris. These Amendments deal with a serious problem arising from double taxation relief and they have been on the Paper for some time, so the obvious arguments for them will doubtlessly have been considered by the Treasury Bench. The first of the three establishes the new principle for computing and assessing overseas tax payable, and Amendment No. 414 makes provision for removing the existing arrangements. In Amendment No. 413, we are putting forward the new principle, and in No. 414, we are proposing that the old one should be taken out. In Amendment No. 415 we are extending to Corporation Tax workings the proposed new principle established in Amendment No. 413 for Income Tax.
I feel that the principle which we are trying to establish is fair and reasonable. It affects only a small number of companies in very special circumstances. First of all, it affects only those overseas companies which trade in more than one foreign country. Apart from that, it affects only those which trade in different countries where the taxation leviable is either higher or lower than that of this country. Clearly, only a small number of companies will be affected, but the way in which they will be affected calls for 1661 special consideration, and I hope that we shall get that consideration tonight.
The Schedule provides for relief to those companies whose income suffers from double taxation, but this relief is given at the United Kingdom rate or at the foreign rate, whichever is the lower. This in itself is not objectionable: in fact, it is a fair arrangement. But, if the corporation trades in several countries where taxation is at different rates, a quite different situation arises. Under this Schedule, the corporation's overseas activities are not treated as a whole, as I think they should be, but each separate activity and each different country is taken on its own. I feel that this proposal is quite indefensible. For these purposes, the corporation's overseas activities should be treated as a whole and not as a series of individual activities.
The result of the Schedule being in its present form that companies of this sort are not getting full relief from United Kingdom taxation in respect of overseas earnings which may be taxed at a higher rate. This arises even though, in some circumstances, the company may have activities in other countries where there is a lower rate of taxation than in the United Kingdom. This ridiculous situation would be far less onerous and objectionable if we were prepared to accept the principle of averaging, in other words, to take those countries where the rate is particularly high and find a balance with those countries where it is low. If this were accepted, our objections to the Schedule in its present form would be removed.
In the Amendment, we are simply trying to get the acceptance of the principle of averaging, which we feel is a fair way of dealing with such a situation. In support of the Amendment, I should like to refer to three special considerations. I have tried to establish the simple general principle of averaging, trying to point out the difficulties which could arise through companies trading in different countries where the tax position is vastly different. Throughout discussion on the Bill, the proposition has been put to us that a corporation will be regarded as something greatly different under the new taxation system. We are told that a corporation has an identity of its own, quite apart from that of its shareholders. 1662 In these circumstances, the Government should accept that an overseas trade corporation or an organisation trading in different countries should be treated as one and its overseas activities treated on one basis.
The second thing which we have to bear in mind is that if these Amendments are not accepted, we shall discourage some companies already trading overseas from trading in certain other territories. Admittedly, this disincentive will not apply to all countries abroad, but it will apply to some. For the good of our nation, those companies already trading abroad are most able to expand their activities in other nations. This is something which should be encouraged and which will be discouraged if the Amendments are not accepted.
The third point is the relevance of this Amendment to the shipping industry. The shipping industry, in particular, trades a good deal in many countries, and sometimes its activity in those countries is of limited duration. In some countries there is the novel development of, so to speak, instant taxation. In india, for instance, when a ship comes into port, taxation is levied on assessed profits at the port, Shipping, perhaps above all other industries, is subject to the full rigours of the Schedule as it stands.
The Amendment would not affect a great number of companies but it would have a most important result for those which it did affect. I hope that the Government will accept it.
§ Mr. MacDermotAs the hon. Member for Glasgow, Cathcart (Mr. Edward M. Taylor) said, the Amendment has been on the Order Paper for some time, and we have had an opportunity to consider it. Incidentally, I am happy to learn that the question which the hon. Member for Nottingham, South (Mr. William Clark) thought to put on the last Schedule does not, in fact, arise on the Schedule at all, so perhaps that is a sufficient explanation of why I was not able to answer it. In any case, I do not think that the answer would have pleased the hon. Gentleman (a) if I were allowed to make it, and (b) if he were here to hear it.
These Amendments are designed to allow the pooling of overseas taxes in respect of which credit is allowable 1663 against United Kingdom tax. As they stand, they would not be acceptable because they go very wide and would afford far too generous a measure of relief. From his experience of these matters, the hon. Gentleman will realise that there are certain fundamental objections in principle to pooling. I shall give one or two of them. A company already operating in a low-tax country could invest in a second country where taxes were high and thereby transfer some or all of the burden of the second country's high taxes to the United Kingdom Exchequer. Conversely, a company already operating in a high-tax country which was contemplating investment elsewhere would have a strong incentive to invest in a low-tax country rather than, for instance, at home.
Both the majority and the minority of the Royal Commission rejected the suggestion that overseas income should be aggregated for the purpose of double taxation relief, considering that a pooling arrangement would go beyond the aim of ensuring by double taxation relief that any United Kingdom charge on overseas profits should do no more than bring the combined rate up to the United Kingdom rate and that pooling would be hard to justify on any view of relative taxable capacity.
But we have received very many and varied representations on this matter. Some companies are in a rather different situation in that they are not carrying on separate trades in different countries but are carrying on one trade the operations in which, by its nature, are carried on in many different places. The most obvious example is a bank with its head office in England which conducts banking operations in various foreign countries. We think that there is some force in the argument in relation to some of these companies, but the Amendments would not offer a satisfactory way of dealing with the situation, apart from the fact that they are in such wide terms. They are silent, for instance, on the difficult problem of how to treat losses. Clearly, any losses ought to go to reduce the measure of any pooled overseas income against which credit could be allowed. Otherwise the taxpayer would be having the best of both worlds.
1664 12.45 a.m.
I do not wish to mislead the Committee in any way. I am not giving an undertaking that we shall be able to find a satisfactory solution to the problem which may be confined to this special kind of case that I have been indicating, but if we can find a way of doing so without its extending over the whole field, we shall be glad to try to achieve that object and, if we are able to, bring forward suitable Amendments. I want to make clear that I am not giving an undertaking that I will bring forward Amendments, but I shall be glad to consider the matter further.
§ Mr. Peter EmeryI thank the Financial Secretary for his undertaking at least to review the position. I do not think that there is a great deal of force in the argument that he used, both now and previously, that if a company is operating in a low-tax country it is likely to look around for a high-tax country in which to invest in order to average. It will invest only if there is a reasonable chance of operation. It is not just a matter of theory in trying to balance it. Having made that point, which formed a considerable part of his argument, I think that it would be foolish of us to divide the Committee on this matter in view of the undertaking which has been given.
Mr. Edward M. TaylorAlthough the hon. and learned Gentleman has promised to look into this, I still feel very disappointed with his reply. The argument put forward about people moving from one country to another to try to ease the tax position is ridiculous. When we consider the difficulties that businessmen have at present, we must accept that people do not just move activities into another country purely from a tax point of view.
I hope that the Chancellor will appreciate the difficulties that businessmen have at present with taxation as it is abroad—when we are trading in Burma where there is a 99 per cent. tax on profits, in Ghana where the tax is more than 60 per cent., in other countries where it varies, and in others where there is a moratorium on all money going out of the country or where, like Indonesia, assets are seized without compensation. It is no joy trading abroad. The Chancellor should take these difficulties into 1665 account and not think of businessmen jumping from one country to another in an attempt to make their tax position easier.
§ Amendment negatived.
§ Mr. MacDermotI beg to move Amendment No. 646, in page 201, line 43, at the end to insert:
(3) In relation to dividends paid by a company resident in the Commonwealth territories, paragraph 3 of Schedule 17 to the Income Tax Act 1952 shall apply as if in that paragraph and (as they apply for purposes of that paragraph) in section 16 of the Finance Act 1964 and sub-paragraphs (1) and (2) above references to one-quarter of the voting power were references to one-tenth of the voting power.
§ The Temporary Chairman (Mr. Grant-Ferris)It will be convenient also to take the following Amendments:
Amendment No. 762, in page 201, line 29, leave out from "Kingdom" to "then" in line 31.
Amendment No. 544, in line 30, leave out "one-quarter" and insert "one-tenth".
Amendment No. 672, in line 31, after "dividends", insert:
or a unit trust or investment trust resident in the United Kingdom".Amendment No. 763, in page 201, leave out lines 39 to 43.Amendment No. 545, in line 40, leave out "one-quarter" and insert "one-tenth".
§ Mr. MacDermotI move the Amendment very briefly because I referred to it during our debate on Clause 60, summarised its effect and gave the reasons why my right hon. Friend thought it right to bring it forward. Its main effect is to reduce from a quarter to one-tenth the minimum proportion of the voting power in a company resident in the Commonwealth territories which a United Kingdom company must control in order to qualify for unilateral relief in respect of underlying tax upon the Commonwealth company's profits.
The qualifying minimum for unilateral relief for investment in Companies outside the Commonwealth will remain at one-quarter. The Committee will remember that it was because of representation about certain companies, particularly mining companies, which are controlled by a consortium of companies in the 1666 United Kingdom that we felt it right to bring forward this Amendment.
We are discussing with it a number of other Amendments which would make further extensions and I must warn the Committee that we do not feel that we can advise it to accept them. It is perhaps better that we should hear what is said about them before I answer further.
§ Mr. EmeryWe have, as those of us who have been present during most of the day know, already gone over a number of points raised on these Amendments in discussing Clause 79. At this hour I have no intention of boring either the Government or my own benches with a repetition of the arguments. We think quite definitely that the Government are right to accept the points that there should be a reduction from one-quarter to one-tenth. This is a very considerable concession and I think that it is enough to accept what the Chancellor is putting forward.
§ Amendment agreed to.
§ Mr. TempleI beg to move Amendment No. 622, in page 201, line 43, at end to insert:
5. Where a company resident in the United Kingdom and carrying on the business of insurance receives any income arising from an investment in a territory outside the United Kingdom being an investment which either—I was rather heartened by our previous successes and thought I might only have to move this Amendment formally but unfortunately the Financial Secretary has indicated a certain amount of disfavour towards its aim. My object is solely concerned with companies carrying on a business of insurance overseas. I think that everyone is seized of the importance of British insurance and wishes to see it carry on and expand its worldwide trade.credit shall be allowed against corporation tax in respect of the income in accordance with Schedule 16 or 17 to the Income Tax Act 1952.
- (a) is required to be made by the law of the territory; or
- (b) is proved to the satisfaction of the Board to be necessary or expedient for the purpose of maintaining or expanding the business carried on in the territory (whether such business is carried on by the company or through a subsidiary),
I want to explain this Amendment under three headings: first, the scope of the insurance business which would be affected; secondly, the [...]cope of the 1667 Amendment and, thirdly, the differentiation between portfolio investment and a trade investment in respect of certain investments of insurance companies overseas.
Everyone realises that London is the home of the world insurance market and that is how we want to keep it. Seventy per cent. of the non-life business of British insurance companies is transacted overseas. British insurance companies have built up reserves outside the United Kingdom not by sending money from the home country but by building up within their overseas businesses.
I see that the Secretary of State for Economic Affairs is here and we welcome him to the Committee. It is not often that we have him with us and I am glad that he is here for this Amendment because insurance business is vital to the whole economy and to the raising of loans for this country in times of difficulty just because we have collateral investments, particularly in the United States.
British insurance has the largest single British investment in the United States of America with£700 million of insurance money invested. Although underwriting in recent years has been unprofitable, earnings from British insurance have been about£50 million a year, coming into Britain across the exchanges. I remind the Committee that because British insurance has been unprofitable, a number of British companies have recently withdrawn entirely from the United States market. It would be extraordinarily unwise of the Government to disregard the importance of British insurance and through their tax proposals to seek to undermine the pre-eminent position of this country in world insurance.
I turn now to the scope of the Amendment. It is entirely directed to insurance companies, and by that I mean limited companies. It seeks to give relief against double taxation in respect of Corporation Tax on the overseas investment income only in two special circumstances. Here I have special regard to the fact that the Chancellor of the Exchequer has said that it is his intention to renegotiate double taxation arrangements with foreign countries.
The two special circumstances which I have picked out in the Amendment are 1668 where an investment of an insurance company has to be held overseas in a specific country because the law of that country requires an insurance company to make an investment in order that it shall be able to write insurance business in that country. In this country we require foreign insurance companies to keep up what is termed a "solvency standard", and in effect that means that foreign insurance companies investing in this country have to hold considerable reserves here.
The second point of the Amendment is that the Board of Inland Revenue would have it within its power to determine whether certain other investments would be treated as trade investments rather than portfolio investments for insurance purposes. It will be within the knowledge of the Committee that in the United States—and I mention the United States only as an example—a British or any other foreign insurance company has to obtain a Best's 5A Rating in order to carry on a first-class business of insurance.
The Best's 5A Rating means that 50 per cent. of its premium income has to be invested in the country where the business is carried on. I am not saying that by law 50 per cent. of its premium income has to be held there, but that by law most insurers in the United States are not allowed to insure with a company which does not have a Best's 5A Rating. Therefore, under this second heading British insurance companies must keep a very large proportion in their investments in the United States. I give that purely as an example of similar arrangements applying in other parts of the world. The Amendment seeks the bare minimum in order to keep British insurance companies operating on their present worldwide scale.
I fully realise that when speaking to the present Government I have to make a sharp differentiation between portfolio and trade investment. This is a question which I shall seek to answer quite directly. I should like to quote the Financial Secretary who said:
…I think that it has generally been agreed in this Committee that there is and can be a great difference in the effect on its returns to this country between trade investment overseas and portfolio investment. It is the trade 1669 investment which is likely to be more productive, and is designed to be productive of helping future trade between ourselves and the countries in which the investment it taking place"—[OFFICIAL REPORT, 16th June, 1965: Vol. 714, c. 575.]1.0 a.m.Therefore, the Financial Secretary to the Treasury recognises that there is an essential difference between portfolio and trade investment. I have to prove that these investments of the insurance companies are trade investments. I do it again under the two headings in my Amendment. Firstly, unless sub-paragraph (a) is complied with, the insurance company concerned cannot trade in any foreign country at all because the law of the country demands that it should make a certain investment in that country before it can carry on the business of insurance. I think it may be accepted that this is a trade investment.
Under (b) I have referred to the Best's rating which is necessary in the United States of America. Unless that particular rating is obtained then no business can be obtained by a British insurance company. Again I have settled law on my side in this particular argument for saying this is trade investment rather than a portfolio investment. As a lawyer the Financial Secretary will know of the case of the Liverpool London Globe v. Bennett settled in 1912. This particular case has been upheld by successive Chancellors, including Sir Stafford Cripps, and I think it would be very unwise not to accept the findings of that particular judgment. This was that it would be unrealistic to separate investment income from underwriting results. What I am asking is that those parts of insurance investment, which under my Amendment would be treated as trade investment, should be treated as trade investments for Corporation Tax double taxation provisions.
I was going to refer to the quite excellent press which this Amendment has had in The Times, the Telegraph and also in the Daily Mail and other responsible newspapers, but I am only going to refer to the Daily Mail, which said that the British Insurance Association had been to the Treasury and the Inland Revenue.
Both the Chancellor and the Inland Revenue looked sympathetic.1670 I am looking across the Committee and I think, judging from the reactions which I am getting from the Treasury Bench, they are not looking quite as sympathetic as they evidently did when they were interviewed by the British Insurance Association. Nevertheless that does not depress me in the least because I believe I have deployed a case which is almost unanswerable and I hope very much that I shall have the support of the First Secretary of State who is very interested in the overall economic situation. Personally I believe Britain is uniquely fitted to be the international insurance centre of the world. Unless we can keep international business in this country our high standard of living cannot be maintained. If this Amendment is not accepted the damage to the British insurance industry may well be incalculable.
§ Mr. MacDermotI am sorry if we gave the impression to the hon. Gentleman the Member for the City of Chester (Mr. Temple) that we were looking at him in an unsympathetic way. We always try to extend the greatest courtesy to his arguments, particularly as they are so forcefully and clearly represented on all occasions. He has made it clear that the intention of his Amendment is to secure that insurance companies which get dividends from overseas companies should remain entitled to unrestricted relief for underlying tax. I must make it clear there are certain technical objections, with which I need not worry the Committee, as to why we could not, in any event, accept this Amendment in the form in which it appears on the Order Paper. As he said, my right hon. Friend has received a number of representations from insurance companies on this matter.
The problem arises particularly in connection with insurance companies operating in such countries as America where, by agreement, there is unrestricted relief for underlying tax. They point out that if they are to carry on their insurance business they must make substantial investments overseas. Perhaps I could refer to America because I think that it is mainly a problem concerned with that country. Not only are there certain minimum requirements to be satisfied, but their status as insurers in America depends on the reserves which they hold 1671 in that country. Moreover, for taxation purposes, they are generally treated as financial concerns, so that the dividend income properly forms part of their trading receipts. I accept, therefore, the hon. Gentleman's argument that there is a real distinction between this investment and what I may call ordinary portfolio investment.
As the hon. Member for the City of Chester said, my right hon. Friend received these representations sympathetically. He wants to consider them carefully. His consideration of the problem is not yet complete, but he can give an assurance that these problems are being considered sympathetically and he will take fully into account all the arguments which have been deployed. I cannot give an undertaking that we will be able to bring forward Amendments to deal with the matter by Report. If we can, we certainly will.
§ Mr. Peter Walker (Worcester)I am surprised that the Government have not introduced an Amendment of their own to cover this very important point. This matter concerns an industry which is probably the biggest single earner of invisible earnings for this country. It has been well known to the Treasury for some time. The moment this Bill was published representations were made by the British insurance industry. The matter has been fully discussed by the Press. I do not understand the statement of the Financial Secretary that he is uncertain about whether anything can be done by Report. This matter is of such fundamental importance to the economy that
§ I should have thought that it was essential that something should have been done by this stage of the Bill, let alone by Report.
§ Here is an industry which is dependent for its very existence abroad on having overseas investments. The Financial Secretary is wrongly informed if he believes that this matter mainly concerns the United States. It is particularly a case which concerns the African and Asian countries which insist on very considerable investment in the countries where British insurance offices operate. In almost every market of the world, with more and more nationalism, there is an insistence that investment takes place in those countries. We have long been the world's greatest insurance market. Already this Bill has dealt considerable blows to the British insurance industry. The thought that the Government are so complacent about this industry that they do not even consider doing anything by Report is alarming.
§ The Amendment is very carefully drawn so as not to include surplus portfolio investment. It is purely confined to investments required for continuing the insurance industry. It has been tabled for three weeks. If in those three weeks a matter concerning the whole British insurance industry cannot be dealt with by the Treasury, it is a very poor reflection on the Treasury. I would certainly urge my hon. Friends to divide on this Amendment.
§ Question put, That those words be there inserted:—
§ The Committee divided: Ayes 283, Noes 289.
1677| Division No. 199.] | AYES | [1.10 a.m. |
| Agnew, Commander Sir Peter | Bessell, Peter | Bullus, Sir Eric |
| Alison, Michael (Barkston Ash) | Biffen, John | Burden, F. A. |
| Allan, Robert (Paddington, S.) | Biggs-Davison, John | Butcher, Sir Herbert |
| Allason, James (Hemel Hempstead) | Bingham, R. M. | Buxton, Ronald |
| Amery, Rt. Hn. Julian | Birch, Rt. Hn. Nigel | Campbell, Gordon |
| Anstruther-Gray, Rt. Hn. Sir W. | Black, Sir Cyril | Carlisle, Mark |
| Astor, John | Blaker, Peter | Cary, Sir Robert |
| Atkins, Humphrey | Bossom, Hn. Clive | Channon, H. P. G. |
| Awdry, Daniel | Bowen, Roderic (Cardigan) | Chataway, Christopher |
| Baker, W. H. K. | Box, Donald | Chichester-Clark, R. |
| Balniel, Lord | Boyd-Carpenter, Rt. Hn. J. | Clark, Henry (Antrim, N.) |
| Barber, Rt. Hn. Anthony | Boyle, Rt. Hn. Sir Edward | Clark, William (Nottingham, S.) |
| Barlow, Sir John | Braine, Bernard | Clarke, Brig. Terence (Portsmth, W.) |
| Batsford, Brian | Brewis, John | Cole, Norman |
| Beamish, Col. Sir Tufton | Brinton, Sir Tatton | Cooke, Robert |
| Bell, Ronald | Brooke, Rt. Hn. Henry | Cordle, John |
| Bennett, Sir Frederic (Torquay) | Brown, Sir Edward (Bath) | Corfield, F. V. |
| Bennett, Dr. Reginald (Gos & Fhm) | Bruce-Gardyne, J. | Costain, A. P. |
| Berkeley, Humphry | Bryan, Paul | Courtney, Cdr. Anthony |
| Berry, Hn. Anthony | Buck, Antony | Craddock, Sir Beresford (Spe[...]thorne) |
| Crawley, Aidan | Iremonger, T. L. | Price, David (Eastleigh) |
| Crosthwaite-Eyre, Col. sir Oliver | Irvine, Bryant Godman (Rye) | Prior, J. M. L. |
| Crowder, F. P. | Jenkin, Patrick (Woodford) | Pym, Francis |
| Cunningham, Sir Knox | Jennings, J. C. | Quennell, Miss J. M. |
| Curran, Charles | Johnston, Russell (Inverness) | Ramsden, Rt. Hn. James |
| Currie, G. B. H. | Jones, Arthur (Northants, S.) | Rawlinson, Rt. Hn. Sir Peter |
| Dalkeith, Earl of | Joseph, Rt. Hn. Sir Keith | Redmayne, Rt. Hn. Sir Martin |
| Dance, James | Kaberry, Sir Donald | Rees-Davies, W. R. |
| Davies, Dr. Wyndham (Perry Barr) | Kerr, Sir Hamilton (Cambridge) | Renton, Rt. Hn. Sir David |
| d'Avigdor-Goldsmid, Sir Henry | Kershaw, Anthony | Ridley, Hn. Nicholas |
| Dean, Paul | Kilfedder, James A. | Ridsdale, Julian |
| Deedes, Rt. Hn. W. F. | Kimball, Marcus | Roberts, Sir Peter (Heeley) |
| Digby, Simon Wingfield | King, Evelyn (Dorset, S.) | Robson Brown, Sir William |
| Dodds-Parker, Douglas | Kirk, Peter | Rodgers, Sir John (Sevenoaks) |
| Doughty, Charles | Lagden, Godfrey | Roots, William |
| Drayson, G. B. | Lambton, Viscount | Royle, Anthony |
| du Cann, Rt. Hn. Edward | Lancaster, Col. C. G. | St. John-Stevas, Norman |
| Eden, Sir John | Langford-Holt, Sir John | Scott-Hopkins, James |
| Elliot, Capt. Walter (Carshalton) | Legge-Bourke, Sir Harry | Sharples, Richard |
| Elliott, R. W.(N'c'tle-upon-Tyne,N.) | Lewis, Kenneth (Rutland) | Shepherd, William |
| Emery, Peter | Li[...]tchfield, Capt. John | Sinclair, Sir George |
| Errington, Sir Eric | Lloyd,Rt.Hn.Geoffrey(Sut'nC'dfleld) | Smith, Dudley (Br'ntf'd & Chiswick) |
| Eyre, Reginald | Lloyd, Ian (P'tsm'th, Langstone) | Smyth, Rt. Hn. Brig. Sir John |
| Farr, John | Lloyd, Rt. Hn. Selwyn (Wirral) | Spearman, Sir Alexander |
| Fell, Anthony | Longden, Gilbert | Speir, Sir Rupert |
| Fisher, Nigel | Loveys, Walter H. | Stainton, Keith |
| Fletcher-Cooke, Charles (Darwen) | Lucas, Sir Jocelyn | Stanley, Hn. Richard |
| Fletcher-Cooke, Sir John (S'pton) | McAdden, Sir Stephen | Steel, David (Roxburgh) |
| Foster, Sir John | MacArthur, Ian | Stodart, Anthony |
| Fraser,Rt.Hn.Hugh(St'fford & Stone) | Mackenzie, Alasdair (Ross&Crom'ty) | Stoddart-Scott, Col. Sir Malcolm |
| Fraser, Ian (Plymouth, Sutton) | Mackie, George Y. (C'ness & S'land) | Studholme, Sir Henry |
| Galbraith, Hn. T. G. D. | Maclean, Sir Fitzroy | Summers, Sir Spencer |
| Gammans, Lady | Macleod, Rt. Hn. Ialn | Talbot, John E. |
| Gardner, Edward | McMaster, Stanley | Taylor, Sir Charles (Eastbourne) |
| Gibson-Watt, David | McNair-Wilson, Patrick | Taylor, Edward M. (G'gow,Cathcart) |
| Giles, Rear-Admiral Morgan | Maginnis, John E. | Taylor, Frank (Moss Side) |
| Gilmour, Ian (Norfolk, Central) | Maitland, Sir John | Teeling, Sir William |
| Gilmour, Sir John (East Fife) | Marples, Rt. Hn. Ernest | Temple, John M. |
| Glover, Sir Douglas | Marten, Neil | Thatcher, Mrs. Margaret |
| Godber, Rt. Hn. J. B. | Mathew, Robert | Thomas, Sir Leslie (Canterbury) |
| Goodhart, Philip | Maude, Angus | Thomas, Rt. Hn. Peter (Conway) |
| Goodhew, Victor | Mawby, Ray | Thompson, Sir Richard (Croydon, S.) |
| Gower, Raymond | Maxwell-Hyslop, R. J. | Thorneycroft, Rt. Hn. Peter |
| Grant, Anthony | Maydon, Lt.-Cmdr. S. L. C. | Tiley, Arthur (Bradford, W.) |
| Gresham Cooke, R. | Meyer, Sir Anthony | Tilney, John (Wavertree) |
| Grieve, Percy | Mills, Peter (Torrington) | Turton, Rt. Hn. R. H. |
| Griffiths, Eldon (Bury St. Edmunds) | Mills, Stratton (Belfast, N.) | Tweedsmuir, Lady |
| Griffiths, Peter (Smethwick) | Miscampbell, Norman | van Straubenzee, W. R. |
| Gurden, Harold | Mitchell, David | Vaughan-Morgan, Rt. Hn. Sir John |
| Hall, John (Wycombe) | Monro, Hector | Vickers, Dame Joan |
| Hall-Davis, A. G. F. | More, Jasper | Walder, David (High Peak) |
| Hamilton, Marquess of (Fermanagh) | Morrison, Charles (Devizes) | Walker, Peter (Worcester) |
| Hamilton, M. (Salisbury) | Mott-Radclyffe, Sir Charles | Walker-Smith, Rt. Hn. Sir Derek |
| Harris, Frederic (Croydon, N.W.) | Munro-Lucas-Tooth, Sir Hugh | Wall, Patrick |
| Harris, Reader (Heston) | Murton, Oscar | Walters, Dennis |
| Harrison, Brian (Maldon) | Neave, Airey | Ward, Dame Irene |
| Harrison, Col. Sir Harwood (Eye) | Nicholls, Sir Harmar | Weatherill, Bernard |
| Harvey, John (Walthamstow, E.) | Nicholson, Sir Godfrey | Webster, David |
| Harvie Anderson, Miss | Noble, Rt. Hn. Michael | Wells, John (Ma[...]dstone) |
| Hastings, Stephen | Nugent, Rt. Hn. Sir Richard | Whitelaw, William |
| Hawkins, Paul | Onslow, Cranley | Williams, Sir Rolf Dudley (Exeter) |
| Hay, John | Orr, Capt. L. P. S. | Wills, Sir Gerald (Bridgwater) |
| Heald, Rt. Hn. Sir Lionel | Orr-Ewing, Sir Ian | Wilson, Geoffrey (Truro) |
| Heath, Rt. Hn. Edward | Osborn, John (Hallam) | Wise, A. R. |
| Hendry, Forbes | Osborne, Sir Cyril (Louth) | Wolrige-Gordon, Patrick |
| Higgins, Terence L. | Page, John (Harrow, W.) | Wood, Rt. Hn. Richard |
| Hill, J. E. B. (S. Norfolk) | Page, R. Graham (Crosby) | Woodhouse, Hon. Christopher |
| Hirst, Geoffrey | Pearson, Sir Frank (Clitheroe) | Woodnutt, Mark |
| Hobson, Rt. Hn. Sir John | Peel, John | Wylie, N. R. |
| Hogg, Rt. Hn. Quintin | Percival, Ian | Yates, William (The Wrekin) |
| Hopkins, Alan | Peyton, John | Younger, Hn. George |
| Hordern, Peter | Pickthorn, Rt. Hn. Sir Kenneth | |
| Hornsby-Smith, Rt. Hn. Dame P. | Pike, Miss Mervyn | TELLERS FOR THE NOES: |
| Howard, Hn. G. R. (St. Ives) | Pitt, Dame Edith | Mr. McLaren and |
| Hunt, John (Bromley) | Pounder, Rafton | Mr. G. Johnson Smith. |
| Hutchison, Michael Clark | Powell, Rt. Hn. J. Enoch | |
| NOES | ||
| Abse, Leo | Armstrong, Ernest | Baxter, William |
| Albu, Austen | Atkinson, Norman | Beaney, Alan |
| Allaun, Frank (Salford, E) | Bacon, Miss Alice | Bellenger, Rt. Hn. F. J. |
| Alldritt, Walter | Bagier, Gordon A. T. | Bence, Cyril |
| Allen, Scholefield (Crewe) | Barnett, Joel | Benn, Rt. Hn. Anthony Wedgwood |
| Bennett, J. (Glasgow, Bridgeton) | Hamilton, James (Bothwell) | Morris, John (Aberavon) |
| Binns, John | Hamilton, William (West Fife) | Murray, Albert |
| Bishop, E. S. | Hamling, William (Woolwich, W.) | Neal, Harold |
| Blackburn, F. | Hannan, William | Newens, Stan |
| Blenkinsop, Arthur | Harrison, Walter (Wakefield) | Noel-Baker, Francis (Swindon) |
| Boardman, H. | Hart, Mrs. Judith | Noel-Baker, Rt.Hn.Philip(Derby,S.) |
| Boston, T. G. | Hattersley, Roy | Norwood, Christopher |
| Boyden, James | Hazell, Bert | Oakes, Gordon |
| Braddock, Mrs. E. M. | Heffer, Eric S. | Ogden, Eric |
| Bradley, Tom | Henderson, Rt. Hn. Arthur | O'Malley, Brian |
| Bray, Dr. Jeremy | Herbison, Rt. Hn. Margaret | Oram, Albert E. (E. Ham, S.) |
| Broughton, Dr. A. D. D. | Hill, J. (Midlothian) | Orbach, Maurice |
| Brown, Rt. Hn. George (Belper) | Hobden, Dennis (Brighton, K'town.) | Orme, Stanley |
| Brown, Hugh D. (Glasgow, Provan) | Holman, Percy | Oswald, Thomas |
| Brown, R. W. (Shoreditch & Fbury) | Horner, John | Owen, Will |
| Buchan, Norman (Renfrewshire, W.) | Houghton, Rt. Hn. Douglas | Padley, Walter |
| Buchanan, Richard | Howarth, Harry (Wellingborough) | Page, Derek (King's Lynn) |
| Butler, Herbert (Hackney, C.) | Howarth, Robert L. (Bolton, E.) | Paget, R. T. |
| Butler, Mrs. Joyce (Wood Green) | Howell, Denis (Small Heath) | Palmer, Arthur |
| Callaghan, Rt. Hn. James | Howie, W. | Pannell, Rt. Hn. Charles |
| Carmichael, Neil | Hoy, James | Park, Trevor (Derbyshire, S.E.) |
| Carter-Jones, Lewis | Hughes, Emrys (S. Ayrshire) | Parker, John |
| Castle, Rt. Hn. Barbara | Hughes, Hector (Aberdeen, N.) | Parkin, B. T. |
| Chapman, Donald | Hunter, Adam (Dunfermline) | Pavitt, Laurence |
| Coleman, Donald | Hunter, A. E. (Feltham) | Pearson, Arthur (Pontypridd) |
| Conlan, Bernard | Hynd, H. (Accrington) | Peart, Rt. Hn. Fred |
| Corbet, Mrs. Freda | Irvine, A. J. (Edge Hill) | Pentland, Norman |
| Cousins, Rt. Hn. Frank | Irving, Sydney (Dartford) | Perry, Ernest G. |
| Craddock, George (Bradford, S.) | Jackson, Colin | Popplewell, Ernest |
| Crawshaw, Richard | Janner, Sir Barnett | Price, J. T. (Westhoughton) |
| Cronin, John | Jay, Rt. Hn. Douglas | Probert, Arthur |
| Crosland, Rt. Hn. Anthony | Jeger, George (Goole) | Pursey, Cmdr. Harry |
| Crossman, Rt. Hn. R. H. S. | Jeger,Mrs.Lena(H'b'n&St.P'cras,S.) | Randall, Harry |
| Cullen, Mrs. Alice | Jenkins, Hugh (Putney) | Rankin, John |
| Dalyell, Tam | Jenkins, Rt. Hn. Roy (Stechford) | Redhead, Edward |
| Darling, George | Johnson, Carol (Lewisham, s.) | Rees, Merlyn |
| Davies, G. Elfed (Rhondda, E.) | Jones, Dan (Burnley) | Reynolds, G. W. |
| Davies, Harold (Leek) | Jones,Rt.Hn.Sir Elwyn(W.Ham,S.) | Rhodes, Geoffrey |
| Davies, S. O. (Merthyr) | Jones, J. Idwal (Wrexham) | Richard, Ivor |
| de Freitas, Sir Geoffrey | Jones, T. W. (Merioneth) | Roberts, Albert (Normanton) |
| Delargy, Hugh | Kelley, Richard | Roberts, Goronwy (Caernarvon) |
| Dell, Edmund | Kenyon, Clifford | Robertson, John (Paisley) |
| Dempsey, James | Kerr, Mrs. Anne (R'ter & Chatham) | Robinson, Rt. Hn.K.(St. Pancras, N.) |
| Diamond, Rt. Hn. John | Kerr, Dr. David (W'worth, Central) | Rodgers, William (Stockton) |
| Dodds, Norman | Lawson, George | Rogers, George (Kensington, N.) |
| Doig, Peter | Leadbitter, Ted | Rose, Paul B. |
| Donnelly, Desmond | Ledger, Ron | Ross, Rt. Hn. William |
| Driberg, Tom | Lee, Rt. Hn. Frederick (Newton) | Sheldon, Robert |
| Duffy, Dr. A. E. P. | Lee, Miss Jennie (Cannock) | Shinwell, Rt. Hn. E. |
| Dunn, James A. | Lever, Harold (Cheetham) | Shore, Peter (Stepney) |
| Dunnett, Jack | Lever, L. M. (Ardwick) | Short,Rt.Hn.E.(N'c'tle-on.Tyne.C.) |
| Edelman, Maurice | Lewis, Arthur (West Ham, N.) | Short, Mrs. Renée (W'hampton,N.E.) |
| Edwards, Rt. Hn. Ness (Caerphilly) | Lewis, Ron (Carlisle) | Silkin, John (Deptford) |
| English, Michael | Lipton, Marcus | Silkin, S. C. (Camberwell, Dulwich) |
| Ennals, David | Lomas, Kenneth | Silverman, Julius (Aston) |
| Ensor, David | Loughlin, Charles | Silverman, Sydney (Nelson) |
| Evans, Albert (Islington, S.W.) | Mabon, Dr. J. Dickson | Skeffington, Arthur |
| McBride, Neil | Slater, Mrs. Harriet (Stoke, N.) | |
| Evans, Ioan (Birmingham, Yardley) | McCann, J. | Slater, Joseph (Sedgefield) |
| Fernyhough, E. | MacColl, James | Small, William |
| Finch, Harold (Bedwellty) | MacDermot, Niall | Smith, Ellis (Stoke, S.) |
| Fitch, Alan (Wigan) | McGuire, Michael | Snow, Julian |
| Fletcher, Sir Eric (Islington, E.) | McInnes, James | Soskice, Rt. Hn. Sir Frank |
| Fletcher, Ted (Darlington) | McKay, Mrs. Margaret | Spriggs, Leslie |
| Fletcher, Raymond (Ilkeston) | Mackenzie, Gregor (Rutherglen) | |
| Floud, Bernard | Mackie, John (Enfield, E.) | Stonehouse, John |
| Foley, Maurice | McLeavy, Frank | Stones, William |
| Foot, Michael (Ebbw Vale) | MacMillan, Malcolm | Strauss, Rt. Hn. G. R. (Vauxhall) |
| Ford, Ben | Mahon, Peter (Preston, S.) | Stross,SirBarnett(Stoke-on-Trent,C.) |
| Fraser, Rt. Hn. Tom (Hamilton) | Mahon, Simon (Bootle) | Summerskill, Hn. Dr. Shirley |
| Freeson, Reginald | Mallalieu,J.P.W.(Huddersfield,E.) | Swain, Thomas |
| Galpern, Sir Myer | Manuel, Archie | Swingler, Stephen |
| Garrett, W. E. | Mapp, Charles | Symonds, J. B. |
| Garrow, A. | Marsh, Richard | Taverne, Dick |
| George, Lady Megan Lloyd | Mason, Roy | Taylor, Bernard (Mansfield) |
| Ginsburg, David | Maxwell, Robert | Thomas, George (Cardiff, W.) |
| Gourlay, Harry | Mayhew, Christopher | Thomas, Iorwerth (Rhondda, W.) |
| Greenwood, Rt. Hn. Anthony | Mellish, Robert | Thomson, George (Dundee, E.) |
| Gregory, Arnold | Mikardo, Ian | Thornton, Ernest |
| Grey, Charles | Millan, Bruce | Tinn, James |
| Griffiths, David (Rothcr Valley) | Miller, Dr. M. S. | Tomney, Frank |
| Griffiths, Rt. Hn. James (Llanelly) | Milne, Edward (Blyth) | Tuck, Raphael |
| Griffiths, Will (M'chester, Exchange) | Molloy, William | Urwin, T. W. |
| Gunter, Rt. Hn. R. J. | Morris, Alfred (Wythenshawe) | Varley, Eric G. |
| Hale, Leslie | Morris, Charles (Openshaw) | Wainwright, Edwin |
| Walden, Brian (All Saints) | Whitlock, William | Wilson, William (Coventry, S.) |
| Walker, Harold (Doncaster) | Wigg, Rt. Hn. George | Winter bottom, R. E. |
| Wallace, George | Wilkins, W. A. | Wyatt, Woodrow |
| Warbey, William | Willey, Rt. Hn, Frederick | Yates, Victor (Ladywood) |
| Watkins, Tudor | Williams, Alan (Swansea, W.) | Zilliacus, K. |
| Weitzman, David | Williams, Clifford (Abertillery) | |
| Wells, William (Walsall, N.) | Williams, W. T. (Warrington) | TELLERS FOR THE NOES: |
| White, Mis. Eirene | Willis, George (Edinburgh, E.) | Mr. Ifor Davics and Mr. Harper. |
§ Mr. MacDermotI beg to move, Amendment No. 647, in page 202, line 14, to leave out sub-paragraph (2).
The Amendment paves the way for the new Schedule, because the provisions of the sub-paragraph are transferred in a slightly amended form to that part of the new Schedule which deals with overspill relief for overseas trading corporations.
§ Amendment agreed to.
§ Schedule, as amended, agreed to.
§ Schedule 16 agreed to.